Performance Systems, Inc., Successor to Minnie Pearl's Chicken System, Inc. v. United States

The action in the District Court was for the recovery of federal corporate income taxes in the amount of $171,572 plus interest, for the taxable year 1967.

Minnie Pearl’s Chicken System, Inc., a Tennessee corporation, was a wholly owned subsidiary of the taxpayer, Performance Systems, Inc., likewise a Tennessee corporation.

The subsidiary filed its initial corporate income tax return for the period ending December 31, 1967, and paid the tax due thereon in the amount of $169,630. Additional taxes amounting to $7,521.28 were assessed against the subsidiary after examination. The subsidiary filed…